I don't see why not. To me, the new rules make more sense than allowing a
Private pilot's entire costs to be paid by someone else.

I see no reason that [the regs should say that] a private pilot's costs
should not be able to be paid by somebody else, and can think of quite a
few examples where it would make sense.

1: My friend who owns a plane flies me for free on a skiing trip. He
breaks his leg. I am prohibited from flying his plane home without
ponying up cash, even if he doesn't want the money. We'd have to hire a
commercial pilot to do this. (well, guess what - in the scenario under
discussion, I would =be= a commercial pilot and could therefore do it,
but a private pilot could not.)

2: My father thinks I should be instrument rated, and offers to pay for
flying lessons and flying time so that I can get my rating. Nixed by
the FAA.

3: I fly three people on Monday, and one person on Tuesday. We share
costs equally. I pay more on Tuesday for the same flight.

4: I'm a member of a ski group - we drive up and whoever is driving
gets free lodging. We've been doing this for years, but this year we
fly. Free lodging is compensation - nixed... though I asked an FAA
official about this and they see it as a separate transaction, so as
long as they don't pay for the =flight=, they can pay as much lodging as
they want and I'm in the clear. Nixed or not? Depends on who has a
burr up which part of whose anatomy that day.

You can argue that these examples are unlikely, but that is besides the
point. The "new" rule (IMEO makes no sense.

Any amount of
money a pilot spends less than his passengers is net profit. Net profit
means commercial enterprise.

This is not the definition of net profit. Net profit is total intake
minus total outgo. The old rule meant "no net profit". The new rule
means something else. As for "net profit meaning commercial
enterprise", that's not true either. Granted a commercial enterprise
will need net profit to stay in business, and will need quite a bit of
net profit. But no commercial enterprise will stay in business (without
subsidy) if "net profit" means "loses as much as their customers", which
is what the new rule actually works out to.

That's ignoring the fact that there is benefit
to the pilot above and beyond any benefit to his passengers.

I like to fly. This joy is a benefit. But if you really mean it that
way then I'm a commercial enterprise when I fly solo.

I make a written record of what transpired, noting how long I was flying
and under what conditions, and keeping track of my flying experience.
This is a benefit inasmuch as I can use it for currency and future
ratings. I know the FAA has put its imprimateur on this twisting of the
meaning of words.

However I cannot =trade on= this "benefit". I can't trade my hours for
a new DG. I can't spend my logbook to buy a hamburger or pay my rent.
If you don't have enough hours for a rating, or lack recent night
landings, I can't "give you some of mine" in exchange for having you
paint my closet. I can't even trade my night landings for your
instrument approaches. The numbers in my logbook are merely a
historical record, they are =not= a medium of exchange.

Therefore, I do not see how the FAA can justify their stance that
logging time is "compensation" that makes one a "commercial operator"
under =any= circumstances (though I will agree that there may be =other=
circumstances which would do so by themselves).

The FAA's opinion is the only one that matters.

Of course. That's why I said it. But that doesn't make the FAA's
opinion make sense. And I didn't add a bunch of qualifications that
weren't in the original. The original (post) simply stated that there
were some circumstances (that is to say, there are not NO circumstances)
in which the commercial ticket would be of use for a pilot who was not
aiming to be a commercial operator. They might be rare, just like
having three pilots log PIC time would be rare, but they are possible.

All that said, I would still be surprised if there are many FBOs that would
be willing to be party to the kind of arrangement being discussed here.

So would I. But an airplane owner might do this. In fact, I think it's
rather common in some circles (such as a company plane used for company
business under part 91).

It
may well be that the FAA's opinion is entirely moot, since no one could
actually attempt this particular end-run around the regulations.

Well, I don't agree with this particular absolute. I'm not even sure
it's all that hard, though I agree that an ordinary FBO is not likely to
do this.

Jose
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